One demand response aggregator has asked MISO market participants not to rely on 2020 data for the 2021/22 enrollment of load-modifying resources.

Voltus said the pandemic-skewed 2020 is not a proper yardstick to measure LMRs against in the 2021/22 planning year. The company said it would not be appropriate for MISO’s load-serving entities and local balancing authorities to make assumptions of LMR performance based on the unusual use patterns and reduced load.

“When registering LMRs for the 2021/22 planning year, it would be unfair to limit LMR megawatt enrollment levels based on summer 2020 load data for loads that were operating at a reduced capacity due to COVID-19,” Voltus said in prepared remarks to MISO’s Steering Committee in a teleconference Tuesday.

MISO’s LSEs and LBAs decide whether to approve LMR enrollments. They typically limit registrations based on capability and load data from the most recent summer.

Voltus Energy Markets Manager Emily Orvis said some public buildings that would have otherwise had air conditioning load were padlocked during the summer.

“Usually, you have schools that hold summer camps, but this year, they didn’t. We don’t want their load-modifying abilities capped on what they could do this year,” she said.

Voltus said MISO should recommend that LSEs and LBAs use 2019 data as an indicator instead of relying on numbers from the past summer.

“They think this can be accomplished outside of the need to redline any Tariff or [Business Practices Manual] language,” MISO stakeholder liaison Jim Kaminski told Steering Committee members.

“While we don’t have a particular position on the issue, we’re certainly willing to look into it,” MISO Manager of Capacity Market Administration Eric Thoms said.

Steering Committee members directed the issue to the Resource Adequacy Subcommittee for further discussion.

If approved, this wouldn’t be MISO’s first adjustment in response the coronavirus pandemic. In July, the RTO allowed market participants to substitute LMRs affected by the pandemic if necessary. (See FERC OKs COVID-19 Waiver for MISO LMRs.) In spring, it also extended by two months a deadline in its interconnection queue for certain generation project hopefuls to demonstrate exclusive land use for projects.